Tax Forum’s self-study courses are designed to provide tax professionals of all experience levels with the perfect combination of conceptual overviews and examples needed to understand and apply flow-through solutions to current tax issues. They are an excellent option for professionals whose day-to-day work schedules can’t accommodate a multi-day program, as well as those who want to concentrate or revisit specific flow-through related topics. All our current courses are detailed below.
INDEPENDENT LEARNING
Self-Study Courses
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1.5 CPE Credit Hours
Planning Opportunities Under §1045
This program examines the requirements for a successful §1045 rollover of the proceeds from the disposition of §1202 stock for which the required five-year holding period has not been satisfied, (2) the extent to which start-up activities satisfy the active trade or business requirement of §1202 and (3) using §1045 to "leverage" the §1202 exclusion by rolling over "excess" §1202 proceeds into multiple qualifying corporations.
Course Fee
$210.00 -
1 CPE Credit Hours
Negative Tax Capital Accounts And Divorce
This program examines the tax consequences of the transfer of property, including partnership interests, between spouses incident to a divorce. As part of this examination, this program will address the basis implications and tangential issues, such as what happens with net operating loss carryovers and passive loss carryovers.
Course Fee
$180.00 -
1 CPE Credit Hours
How to Make §704(b) Allocations When There Are Preferred Returns
This program delves into the controversial issue as to whether a gross income allocation is required to be made when (1) there is a partner (“preferred partner”) who is entitled to a preferred return on capital, (2) there is §704(b) capital of other partners that is subordinate to the preferred partner entitled to the preferred return, and (3) the partnership breaks even for the year.
Course Fee
$180.00 -
1.5 CPE Credit Hours
Traps to Avoid When Converting a Partnership to a Corporation
This program is designed to identify situations where it may be beneficial to incorporate a partnership, as well as to drill down many of the tax considerations from the perspective of both the corporation and the partners or partnership (as applicable) when engaging in a partnership incorporation transaction.
Faculty
Course Fee
$210.00 -
1.5 CPE Credit Hours
The Evolving Thought Process on Tax Distributions
This course focuses on the various considerations in structuring an effective partnership tax distribution provision and the different perspectives of partners holding different “classes” of interest when negotiating a tax distribution provision.
Faculty
Course Fee
$210.00 -
2 CPE Credit Hours
F Reorganizations, §704(c) Considerations For Rollover Equity and More
This course focuses on the tax considerations when engaging in a part-sale/party rollover transaction by an S corporation using an F reorganization structure, including FEIN retention, the §704(c) decision-making matrix with respect to the rollover equity, and how tax basis is allocated with respect to the sale portion of the partnership interest in the part-sale/part-rollover transaction.
Faculty
Course Fee
$240.00 -
1.5 CPE Credit Hours
Serial Redemptions in a Personal Service Partnership
This course focuses on the various federal income tax consequences of serial redemption payments made to a retired service partner in a personal service partnership and the choices that the parties have in structuring the tax consequences of those payments.
Faculty
Course Fee
$210.00 -
0.5 CPE Credit Hours
What To Do About a Blown §83(b) Election
This program first describes a couple of approaches that may be taken if unvested corporate stock is provided to a service provider and the service provider fails to make a §83(b) election and discovers the failure after the 30-day due date for filing the §83(b) election. The program then switches to the partnership arena and examines (1) the requirements of making a §83(b) election for unvested property received by the partnership’s service provider; (2) when a discretionary §83(b) election should be considered in connection with the receipt of a partnership profits interest; and (3) what steps may be taken if a §83(b) election were not made for a partnership profits interest and the IRS safe harbor for not making a §83(b) election is not available.
Faculty
Course Fee
$210.00 -
3 CPE Credit Hours
Planning and More Under the S Corporation §1374 Built-in Gain Rules
This program begins with a review of the basics of the §1374 built-in gain rules and how the built-in gains tax potentially applies during the five-year recognition period to the disposition of appreciated assets owned by an S corporation as of the effective date of its conversion from C corporation status. The program then addresses: (1) the limitations on the amount of the built-in gains tax; (2) the importance of the timing of disposition of built-in gain and loss assets; (3) how to minimize or eliminate the built-in gains tax impact of cash-basis accounts receivable owned by the S corporation as of the effective date of its S election; (4) how the built-in gains tax applies to collections of an installment note held by the S corporation as of the effective date of its S status; and (5) how the built-in gains tax applies to assets disposed of by a partnership in which the S corporation owns an interest.
Faculty
Course Fee
$300.00 -
1 CPE Credit Hours
Continuing S Corp Shareholders: Navigating Pro Rata Allocation After an Asset Sale
This program examines how to structure a sale of assets of an S corporation using multiple installment notes and the 12-month liquidation provisions of §453B(h) and §453(h) where there will be rollover equity that is owned by one of the shareholders, so that the S corporation shareholders recognize gain at different times.
Course Fee
$180.00 -
2 CPE Credit Hours
The Revised §752 Regulations
This program examines the 2019 regulatory changes to the manner in which debt is classified as either recourse, nonrecourse or partner nonrecourse debt for §752 purposes, specifically focusing on when guarantees of debt and indemnities of partner guarantors of partnership debt will be respected for §752 basis purposes. The program also will examine how these changes may interact with the determination of whether a partner guarantee of partnership debt or a partner indemnity of a partner guarantor of partnership debt will be treated for §465 at-risk purposes.
Faculty
Course Fee
$240.00 -
1 CPE Credit Hours
Code §751 Hot Asset Reporting and the Proposed §751 Regulatory Changes to the Computation of Hot Assets
This program examines the current definition of §751 hot assets and the proposed 2014 regulatory changes to the manner in which substantial appreciation is computed for determining whether inventory items are substantially appreciated. In this regard, the program focuses on the considerations of whether to opt into the proposed regulations. The program also will discuss the partnership hot asset reporting requirements and the impact of proposed regulatory changes in this arena.
Course Fee
$180.00 -
3 CPE Credit Hours
The §465 At-Risk Rules: Important Concepts
The program begins with a discussion of the §465 at-risk rule basics and how to compute and report a taxpayer's amount at-risk. The program then addresses: (1) the impact of debt guarantees; (2) borrowing from someone who has an interest in an activity other than as a creditor; (3) what is the activity of holding real property for purposes of classifying nonrecourse debt as "qualified nonrecourse debt"; and (4) when activities can be aggregated.
Faculty
Course Fee
$300.00
Emerging Issues and Insights
In-depth analysis of topics of interest to tax planning professionals